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HVAC Ductless Systems

Waiver type - Procurement: Nonavailability

Agency: FEDERAL AVIATION ADMINISTRATION (6920) • Product Service Code (PSC) : 4120 | Last Modified: 06/06/2025

Procurement Summary

The Contracting Officer posted a request for information on SAM.gov on 28 March 2024 with a response date of 8 April. Two responses were received, the first from UKT Air Conditioners and the units they offered did meet the Buy American Preference criteria but did not produce systems in the size and capacity required. The units provided are made for small office spaces or bedrooms. The second response from Blue Jacket Industries, which provided cut sheets on products such as Daiken, Mitsubishi, and Pioneer, have previously been reviewed by the Contracting Officer and found not compliant with the Buy American Preference. The FAA is aware of one supplier of a compliant product: Johnson Controls who is the controlling entity of Trane, York, Goodman, Coleman, and others. Trane has partnered with Mitsubishi to provide and sell VRF units under the Trane name. They admit through a letter that they do not meet the Buy American Preference requirements. They also state that none of their ductless mini-split units are produced or manufactured in the U.S. Additional market research has been conducted in the past six months through internet research and discussions with subject matter experts (SMEs) within the HVAC industry. Through these discussions and emails with SMEs, none of the ductless HVAC mini-splits in the size and capacity needed are produced or manufactured within the United States. After discussions with industry experts, they have indicated that the ductless mini-splits are expected to be another two to three years away to be compliant with the BAA requirements. The leading manufacturers are not capable of producing the ductless units in the size and capacities the FAA is needing due to new production lines and the technology to be added to the current locations within the U.S. A previous waiver was approved in June 2024 for the same type of units. Additional market research through the internet was conducted to find possible changes to the market. The market has not changed, and no BAA Compliant manufacturers have been found. Continued research was conducted on 4/29/25 on the Made in America Office website with several waivers submitted requesting the same equipment. The most recent was posted on 2/6/25 by the Dept of the Army and another posted 1/17/25 by the U.S. Coast Guard. Continued market research over the past year continues to provide the same result of no U.S. manufacturers of the Ductless HVAC Mini-Split systems as indicated from the MIAO with other agencies requesting the same types of units.

Waiver Rationale Summary

The FAA is aware of the supplier of a compliant product: Johnson Controls who is the controlling entity of Trane, York, Goodman, Coleman and others. Trane has partnered with Mitsubishi to provide and sell VRF units under the Trane name. They have provided a letter stating they do not meet the Buy American Preference Requirements. They also state that none of their ductless mini-split units are produced or manufactured within the U.S.

Did / Will the solicitation include one of the standard BAA provisions announcing the agency’s intention to provide a price preference for domestic end products and construction material?

Yes

Was a sources sought or Request for Information issued?

Yes

OMB Determination

Consistent with Policy

Product

AIR CONDITIONING EQUIPMENT

NAICS

423730 - Warm Air Heating and Air-Conditioning Equipment and Supplies Merchant Wholesalers

Date Submitted

05/15/2025

Procurement Instrument Identifier (PIID)

N/A

Solicitation ID

N/A

Procurement Stage

Pre-solicitation

Expected Maximum Duration of the Proposed Waiver

Between 1 and 2 years

Waiver Coverage

Individual Waiver

Funding Agency

FEDERAL AVIATION ADMINISTRATION